Authored By: Dua-e-Batool
University of London
Introduction
A thriving service industry would ordinarily be expected to provide its workers with fair and well-regulated working conditions. In Pakistan, however, this does not always seem to be the case when it comes to the beauty and personal care industry. While high-end salons generate significant profits, the female workers who form the backbone of these establishments may face a very different reality, including exploitation, limited access to statutory protections, and poor working conditions. Practices that benefit the industry may, in some cases, come at the expense of the rights of salon workers. These workers may face issues such as non-payment of statutory minimum wages, excessive working hours without overtime compensation, exposure to chemical hazards, and workplace harassment.[1]
This regulatory breakdown occurs not because of an absolute statutory void, but because of a failure in legal application. Although Pakistani labour statutes appear to cover employees in the commercial service sector, salon workers remain effectively invisible due to informal employment arrangements, non-registration of establishments, and restrictive statutory definitions.[2]
This article argues that Pakistan’s existing labour framework does not adequately protect female salon workers, largely due to gaps in enforcement, restrictive statutory definitions, and the informal nature of much of the beauty sector. It therefore examines whether targeted legislative reform and stronger regulatory oversight are necessary to ensure that these workers can effectively access the protections available under the law.
The article proceeds as follows. Section II sets out the constitutional and statutory framework applicable to salon workers. Section III evaluates the gap between legal protection and its practical enforcement. Section IV examines comparative approaches from India and the United States. Section V proposes reforms aimed at improving formalisation, enforcement, and occupational safety.
The Existing Legal Framework
Constitutional Rights
The Constitution of the Islamic Republic of Pakistan, 1973, provides constitutional protections relevant to labour welfare. Article 11 prohibits slavery, forced labour and trafficking in human beings. Article 25 guarantees equality before the law and prohibits discrimination based on sex, while permitting the State to make special provisions for the protection of women. Article 37(e) directs the State to secure just and humane conditions of work, ensure that women are not employed in vocations unsuited to their sex or age, and provide for maternity benefits.[3]
Commercial Establishments and Minimum Wage Legislation
Beauty salons and parlours fall within the scope of provincial commercial establishment and labour legislation. Following the devolution of labour matters to the provinces, Sindh has developed its own statutory framework governing working conditions and minimum wages. The Sindh Shops and Commercial Establishment Act, 2015 regulates matters including working hours and overtime, while the Sindh Minimum Wages Act, 2015 establishes the framework for fixing minimum wages for workers in industrial and commercial establishments.[4]
Under section 8 of the Sindh Shops and Commercial Establishment Act, 2015, an adult employee cannot be required or permitted to work for more than nine hours a day or forty-eight hours a week. Section 9 further provides that overtime work must be paid at twice the ordinary rate of wages.[5]
The minimum wage framework also distinguishes between different categories of workers, including unskilled, semi-skilled, skilled, and highly skilled workers. The minimum monthly wage for unskilled workers in Sindh was increased to Rs 43,000 from 1 July 2026, with higher minimum rates applicable to other categories. The wage notifications also recognize occupations within the Hair Salon and Beauty Clinics Industry, including beauticians, hairdressers, makeup artists, assistants and helpers, placing different occupations within the relevant wage categories.[6]
Accordingly, the statutory framework provides both working hours and wage protections for workers in commercial establishments, including those employed in the beauty sector.[7]
In Sindh, Standing Order 2 of the Sindh Terms of Employment (Standing Orders) Act, 2015 requires terms and conditions of service to be given in writing to workers to whom the Act applies.[8]
Gender-Specific and Health Protections
Female workers are also protected under the Protection Against Harassment of Women at the Workplace Act, 2010, which was amended in 2022. The amendment expanded the definitions of “employee”, “employer” and “workplace” to include a wider range of workers and work environments, including informal and non-traditional workplaces. The Act also requires every organization to establish a three-member Inquiry Committee and display the Code of Conduct. In addition, provincial occupational safety and health laws, such as the Sindh Occupational Safety and Health Act, 2017, place duties on employers to protect the safety and health of workers and identify and assess workplace hazards.[9]
III. Critical Evaluation of Labour Rights in the Beauty and Salon Industry
Informal Employment and Lack of Formalization
Although Pakistani labour legislation provides protections for workers, the informal nature of employment in the beauty industry can make these protections difficult to access. Salon workers may be employed through informal arrangements, including trainee, temporary or commission-based arrangements, which can make the actual employment relationship unclear. Reports on the Pakistani salon industry have documented workers being described as apprentices or trainees while performing regular salon work, alongside concerns regarding low wages, long working hours and a lack of employment benefits.[10]
This creates a gap between the protection provided by legislation and the position of workers in practice. The Sindh Terms of Employment (Standing Orders) Act, 2015 applies to commercial establishments employing ten or more workers and requires written terms of service for covered workers. Smaller establishments may therefore fall outside of this particular formalisation requirement. This does not remove other protections, such as minimum wage and working-hour legislation, but it can leave smaller establishments with fewer formal employment requirements.[11]
The issue is therefore not simply whether salon workers are legally protected, but whether their employment is sufficiently formalised for those protections to be effectively recognised and enforced. This is particularly important in an industry where many establishments are small, and employment arrangements may be informal.
Wages and Working Hours
The legal framework discussed above provides clear protections concerning minimum wages, working hours, and overtime. However, reports on the Pakistani salon industry suggest that these protections are not always reflected in working conditions. A report on beauty salons in Pakistan documented working days of nine to twelve hours, low salaries and instances where workers were not receiving benefits available to employees. More recent reporting has similarly described salon workers working from morning until late evening, with some reporting that they were not paid for overtime.[12]
These reports demonstrate the difference between statutory protection and its practical application. For example, the Sindh Shops and Commercial Establishment Act, 2015 limits adult working hours and requires overtime to be paid at twice the ordinary rate. Similarly, the minimum wage notifications specifically recognize occupations within the Hair Salon and Beauty Clinics Industry. The existence of occupation-specific wage rates is significant because it shows that salon workers are not excluded from the minimum wage framework simply because they work in the beauty sector.[13]
The problem therefore appears to lie less in the absence of wage legislation and more in compliance and enforcement. Where workers are paid through commissions, described as trainees or employed without clear written terms, it may also become more difficult for them to establish whether the wages they receive comply with the statutory minimum. This creates a practical barrier to exercising rights that already exist under the law.
Harassment and Occupational Health
The nature of salon work also creates concerns relating to harassment and occupational health. Salon workers interact directly with clients and may work in close or private spaces, making effective protection against harassment particularly important. The 2022 amendments to the Protection Against Harassment of Women at the Workplace Act broadened the categories of workers and workplaces covered by the legislation. However, the existence of a legal complaint mechanism does not necessarily mean that workers are able or willing to use it.[14]
The problem is particularly significant where workers are financially dependent on their employers or have limited knowledge of their legal rights. A worker may therefore hesitate to make a complaint where doing so could affect her employment. Effective protection consequently requires not only an Inquiry Committee on paper, but also an accessible and trusted mechanism through which complaints can be made.
Occupational health presents a similar concern. Salon workers may regularly come into contact with hair dyes, nail products, and other chemical substances. International occupational safety research has identified chemicals such as formaldehyde, toluene, and other substances used in salon products as potential workplace hazards. The United States Occupational Safety and Health Administration, for example, has identified respiratory, skin and other health risks associated with chemical exposure in salons and requires protective measures where relevant standards apply.[15]
This does not mean that the same level of exposure or regulatory failure has been established across Pakistani salons. However, it demonstrates why occupational safety legislation is relevant to the beauty industry. The absence of adequate ventilation, protective equipment, training, or awareness can turn routine salon work into a potential occupational health risk.[16]
Enforcement Gaps
The most significant difficulty is therefore the enforcement of existing labour protections. Pakistan already has legislation addressing minimum wages, working hours, written employment terms, harassment and occupational safety. The problem is whether these laws effectively reach workers employed in informal or smaller establishments.
The issue of enforcement is not unique to the beauty industry. Pakistan’s Ministry of Human Rights has identified the need for stronger labour inspection mechanisms, including regular inspections of businesses operating in the informal economy and greater participation of women as labour inspectors. The International Labour Organization has similarly highlighted the need to expand labour law coverage to the informal economy and increase the number of female labour inspectors.[17]
This is particularly relevant to the salon industry because many workers are women and many establishments are small. A legal framework can provide rights, but those rights have limited practical value if workers do not know about them, establishments are not inspected, or workers have no realistic means of bringing violations to the attention of authorities.
The central problem is therefore implementation. Pakistan’s labour framework provides several protections that can apply to salon workers, but informality, limited enforcement and unequal bargaining power can prevent those protections from being realised in practice.
Comparative Perspectives
Other jurisdictions demonstrate ways in which labour protection can be extended to workers operating outside traditional employment structures. In India, the Code on Social Security, 2020 expressly provides a framework for extending social security to workers in the organised and unorganised sectors. India has also established the e-Shram portal as a national database for unorganized workers, including gig and platform workers, with the aim of facilitating access to social security and welfare schemes.[18]
This approach is relevant to Pakistan because it recognizes that workers should not become invisible simply because their employment does not fit a traditional model. A registration system could similarly help identify workers in Pakistan’s informal service sector and connect them with existing labour protections.
These examples do not mean that Pakistan should directly adopt foreign systems. Rather, they demonstrate that labour regulation can be adapted to industries where informal employment and occupation specific risks make traditional enforcement difficult.
Recommendations
The first step should be to improve the formal recognition of salon workers. Written employment terms should be encouraged and, where legally applicable, effectively enforced so that workers clearly know their wages, working hours and conditions of employment. Digital or standardised employment contracts could also make it easier for workers and labour authorities to establish the existence and terms of an employment relationship.[19]
Second, labour inspection should be strengthened within the beauty sector. Inspections should include smaller establishments and should focus on compliance with minimum wage, working hours, overtime, and occupational safety requirements. Greater participation of female labour inspectors would also help address the practical difficulties involved in inspecting workplaces employing predominantly women.[20]
Third, workers should have greater access to information about their legal rights. Salons could be required to display information regarding minimum wages, working hours, overtime, and procedures for making harassment complaints. This would allow workers to identify violations without having to rely entirely on employers for information about their rights.
Fourth, occupational safety requirements should be given greater attention in the beauty industry. Workers should receive basic training regarding chemical products, ventilation, and protective equipment. Employers should also be encouraged to maintain appropriate safety measures and provide workers with information about the products they use.[21]
Finally, Pakistan could consider a registration mechanism for informal beauty workers. A simple registration system could help identify workers who currently operate outside formal employment structures and could provide a basis for extending social protection and labour-related services to them. India’s e-Shram system provides one example of how a national database can be used to identify unorganised workers and facilitate access to welfare schemes.[22]
Conclusion
The legal framework governing labour rights in Pakistan provides several protections that are relevant to women working in the beauty and salon industry. Constitutional provisions, minimum wage legislation, working-hour requirements, protection against harassment, and occupational safety laws collectively establish a framework for protecting these workers.[23]
However, the existence of legislation does not necessarily translate into effective protection. Informal employment arrangements, smaller establishments, limited awareness and weaknesses in labour inspection can prevent salon workers from accessing rights that already exist. The central issue is therefore not simply the absence of law, but the gap between legal protection and its practical enforcement.
Protecting women in Pakistan’s beauty industry requires stronger implementation of existing legislation alongside measures that recognise the informal nature of the sector. Greater formalisation, improved labour inspections, accessible complaint mechanisms, occupational safety measures, and worker registration could help close this gap. Ultimately, the profitability and growth of the beauty industry should not come at the expense of the women whose labour sustains it.
Bibliography
Primary Sources
Legislation
Constitution of the Islamic Republic of Pakistan 1973
Protection against Harassment of Women at the Workplace Act 2010
Sindh Minimum Wages Act 2015
Sindh Occupational Safety and Health Act 2017
Sindh Shops and Commercial Establishment Act 2015
Sindh Terms of Employment (Standing Orders) Act 2015
Foreign Legislation
Code on Social Security 2020 (India)
Government Notifications & Reports
Government of Sindh, Labour and Human Resources Department, Minimum Wages Notification 2026–27 (17 August 2026)
Secondary Sources
Articles, Institutional Reports & Web Sources
Chaudhry A, ‘The Real Lives Of Salon Girls’ (Dunya Digital, 20 January 2025)
International Labour Organization, ‘Strengthening Labour Inspection system for Promoting Labour Standards and ensuring workplace compliance in Pakistan – Final evaluation’ (5 August 2020)
Ministry of Human Rights, Government of Pakistan, ‘Labour Standards and the Informal Economy’
Ministry of Labour and Employment, Government of India, ‘About e-Shram Portal’
Occupational Safety and Health Administration, ‘Hair Salons: Facts about Formaldehyde in Hair Products – Protecting Worker Health’ (US Department of Labor)
Occupational Safety and Health Administration, ‘Health Hazards in Nail Salons – Overview’ (US Department of Labor)
Zai NM, ‘The ugliness within beauty salons’ (Geo News, 22 June 2017)
[1]Natasha Mohammad Zai, ‘The ugliness within beauty salons’ (Geo News, 22 June 2017).
[2]The Constitution of the Islamic Republic of Pakistan, 1973, Arts 11, 25, 37(e); Sindh Shops and Commercial Establishment Act 2015; Sindh Minimum Wages Act 2015; Sindh Terms of Employment (Standing Orders) Act 2015, Standing Order 2.
[3] The Constitution of the Islamic Republic of Pakistan, 1973, Arts 11, 25, 37(e).
[4] Sindh Shops and Commercial Establishment Act 2015; Sindh Minimum Wages Act 2015.
[5] Sindh Shops and Commercial Establishment Act 2015, ss 8–9.
[6] Government of Sindh, Labour and Human Resources Department, Minimum Wages Notification 2026–27 (17 August 2026).
[7] Sindh Shops and Commercial Establishment Act 2015; Government of Sindh, Minimum Wages Notification 2026–27.
[8] Sindh Terms of Employment (Standing Orders) Act 2015, Standing Order 2.
[9] Protection against Harassment of Women at the Workplace Act 2010 (as amended 2022); Sindh Occupational Safety and Health Act 2017.
[10] Natasha Mohammad Zai, ‘The ugliness within beauty salons’ (Geo News, 22 June 2017); Amna Chaudhry, ‘The Real Lives Of Salon Girls’ (Dunya Digital, 20 January 2025).
[11] Sindh Terms of Employment (Standing Orders) Act 2015, Standing Order 2.
[12] Zai (n 10); Chaudhry (n 10)
[13] Sindh Shops and Commercial Establishment Act 2015, ss 8–9; Government of Sindh, Minimum Wages Notification 2026–27.
[14] Protection against Harassment of Women at the Workplace Act 2010 (as amended 2022).
[15] Occupational Safety and Health Administration, ‘Health Hazards in Nail Salons – Overview’ (US Department of Labor); Occupational Safety and Health Administration, ‘Hair Salons: Facts about Formaldehyde in Hair Products – Protecting Worker Health’ (US Department of Labor).
[16] Sindh Occupational Safety and Health Act 2017.
[17] Ministry of Human Rights, Government of Pakistan, Labour Standards and the Informal Economy; International Labour Organization, Strengthening Labour Inspection system for Promoting Labour Standards and ensuring workplace compliance in Pakistan (5 August 2020).
[18] Code on Social Security 2020 (India); Ministry of Labour and Employment, Government of India, ‘About e-Shram Portal’.
[19] Sindh Terms of Employment (Standing Orders) Act 2015.
[20] Ministry of Human Rights (n 17); ILO Report (n 17).
[21] OSHA Guidelines (n 15); Sindh Occupational Safety and Health Act 2017.
[22] Code on Social Security 2020 (India); e-Shram Portal.
[23] The Constitution of the Islamic Republic of Pakistan, 1973.
